In the October Kete Kupu issue, NZCCSS Executive Officer Trevor McGlinchey signaled the major concerns in the community sector about the way the Ministry of Social Development (MSD) is seeking to require sharing of client information held by non-government organisations that are contracted to the Ministry to provide social services in all contracts by mid-2017. Social service providers are independent agencies that wish to provide support to people in often very challenging situations and see this new requirement as a major problem.
In response to these concerns, the combined community sector organisations ComVoices group drafted up an issues paper The Community Sector and the Collection of Individual Client Level Data that was presented to MSD in November. Following on from this, a working party has been established between the MSD, the CommVoices group, and MSD’s NGO Advisory Group to continue the discussion about agreeing appropriate ways to deal with data sharing.
The issues covered in the paper include:
- The rationale for collecting individual data
- MSD’s protocols for collecting and holding personal information
- Compliance and infrastructure
- Privacy considerations
- Liability if Privacy is Breached
- Lack of consultation
- Potential for Rationing of Services
As the paper makes clear, “there are significant risks for both MSD and providers in implementing requirements for collecting and providing Individual Client Level Data in contracts before appropriate protocols and mechanisms have been worked through. We would like to work urgently with MSD to ensure that these risks are jointly identified and strategies are developed to mitigate them. This should include a thorough and system wide Privacy Impact Assessment and joint planning to mitigate risk exposure and manage implementation.”